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Interpretation Response #15-0141

Below is the interpretation response detail and a list of regulations sections applicable to this response.

Interpretation Response Details

Response Publish Date: 09-21-2015
Company Name: Daniels Training Service    Individual Name: Mr. Daniel Stoehr
Location state: IL    Country: US

View the Interpretation Document

Response text:

September 21, 2015

Mr. Daniel Stoehr
Daniels Training Service
P.O. Box 1232
Freeport, IL 61032

Ref. No. 15-0141

Dear Mr. Stoehr:

This responds to your July 7, 2015 request for clarification of the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180) as they apply to the incident reporting requirements for excepted packages of Class 7 (radioactive) material. Specifically, you suggest that there is an error in § 173.422(c), which incorrectly references § 175.700(b) instead of § 175.705.

As currently drafted, § 173.422(c) requires excepted packages that are leaking or from which a release has occurred to comply with the reporting requirements in §§ 174.750, 175.700(b), or 176.710 dependent on the mode of transportation. In a final rule published under Docket Number RSPA-02-11654 (HM-228) [71 FR 14586], the reporting requirements for Class 7 (radioactive) material transported by air were moved from § 175.700(b) to § 175.705 without a corresponding revision to § 173.422(c). We will correct this reference in a future rulemaking. In the interim, we recommend that incidents involving excepted packages of Class 7 (radioactive) material transported via air comply with the requirements prescribed in § 175.705 since the present § 175.700(b) is not relevant to incident reporting.

I hope this information is helpful.



Duane Pfund
International Standards Coordinator
Standards and Rulemaking Division


175.700(b), 175.705, 173.422(c), 174.750

Regulation Sections

Section Subject
§ 174.750 Incidents involving leakage